loan-comparison

---
name: loan-comparison
description: Turns a stack of finance offers with different rates, fees and terms into one ranked table on total cost: every quote broken into its rate, every fee, its basis and its term, a regulated status check that explains why most business lending carries no standardised comparable rate at all, an early settlement position read from the actual contract rather than assumed, a broker commission disclosure check, and a single total cost of credit figure per offer sorted from cheapest to dearest. Use once you are holding two or more real quotes and need to compare them honestly rather than by the number printed largest on the page.
---

# Every offer reduced to one honest number: what it actually costs you, start to finish

You give this two or more finance quotes exactly as the lenders or brokers gave them to you. You get back each quote broken into its rate, every fee with its basis, its term and any final payment, a note on whether it is regulated credit or exempt business lending and why that matters for how it was advertised to you, the early settlement position read from the contract rather than assumed, a broker commission disclosure check where a broker is involved, and one total cost of credit figure per quote, in pounds, sorted from cheapest to dearest. It will not tell you which one to take. It will not average anything, guess at a missing fee, or fill a gap with what a similar facility usually costs, because no such average is published for a single independent UK business and a filled gap is a wrong answer wearing a right answer's clothes.

## What it does

1. **Understand before comparing anything that most business lending publishes no standardised comparable rate at all, and that this is exactly why this skill exists.** A credit agreement is exempt from the Consumer Credit Act regime where "the lender provides the borrower with credit exceeding £25,000" and the agreement is "entered into by the borrower wholly or predominantly for the purposes of a business carried on, or intended to be carried on, by the borrower." Consumer lending carries a mandatory, standardised representative APR precisely so two very different products can be compared on one number. Exempt business lending carries no equivalent duty. The British Business Bank's own glossary still recommends the comparison: APR is "a useful way to compare how much interest you would pay on loans from different providers", and elsewhere it advises reviewing "the APR (Annual Percentage Rate), which incorporates any fees charged by the lender for the loan service." But nothing compels a business lender to quote one in a standardised way, which is why an owner comparing real business quotes cannot simply read off the APR box and needs to build the number themselves.

2. **Write every quote onto one row before judging any of them, in the lender's own words.** Lender name, product name, amount, rate and whether it is fixed or variable, every fee by name with its amount and basis, the term in months, the repayment frequency, and any final or balloon payment. Copy figures from the actual quote document, never from a phone call summary or a broker's headline email, because the number that matters is the one in the contract, not the one in the pitch.

3. **Check the regulated status of each quote, because it changes what the advertisement was legally required to tell you.** Mark each quote regulated, exempt business lending, or company borrowing, using the £25,000 and business purpose test. Where the Committee of Advertising Practice's rules on financial products apply at all, a marketing communication for a product not regulated by the FCA must still meet a basic standard: it "should state the nature of the contract being offered, any limitation, expense, penalty or charge and the terms of withdrawal", and "the basis used to calculate any rate of interest, forecast or projection must be apparent immediately." That is a real but modest duty. It is not the same as the detailed, standardised representative example format the FCA's own Consumer Credit sourcebook requires for regulated consumer credit promotions, which is why two exempt business quotes can look identically professional and still be built on completely different fee structures underneath.

4. **Build the total cost of credit for every quote as one number, not as a rate and a fee sitting in separate cells.** Amount advanced, plus every fee, plus every interest or rental payment across the full term, minus the amount advanced, equals the total cost of credit. Write it in pounds, not as a percentage, because a percentage hides the term: a 12 percent facility over eighteen months and an 8 percent facility over three years are not the cheaper and dearer facility in the order their headline rates suggest once the actual pounds are added up. Divide the total cost of credit by the amount borrowed and multiply by 1,000 to get a cost per 1,000 pounds borrowed figure too, because it makes offers of different sizes genuinely comparable on the page.

5. **Read the early settlement clause in the actual contract, and do not assume any statutory protection applies.** The rebate formula that gives a consumer borrower money back for paying a loan off early is set out in the Consumer Credit (Early Settlement) Regulations 2004, and its own text names its scope: the obligation applies "under a regulated consumer credit agreement." An exempt business loan is not one. There may be a contractual early settlement term, there may be none, and the only way to know is to read the clause the lender actually wrote, then record it against that quote rather than assuming a fair, standardised rebate is baked in by law the way it would be for a personal loan.

6. **Check whether a broker is involved, and record the commission disclosure separately from the loan's own regulated status, because the two are not the same question.** A broker introducing a business to a lender remains a credit broker under the regulated activities regime "whether the agreement is regulated or exempt", meaning broking a loan that is itself exempt business lending can still be a regulated activity in its own right. Where a regulated broker is involved, the rule is specific: a firm must "indicate to the customer in a prominent way the existence and nature of any financial arrangements with a lender that might impact upon the firm's impartiality." Ask directly whether the broker is paid by the lender, by you, or both, and record the answer against the quote it relates to, because a broker's incentive is part of the true cost of a quote even where it never appears as a line item.

7. **Never let a monthly payment figure stand in for the comparison.** A lower monthly payment can be produced by a longer term, a larger final payment, or fees added to the balance rather than charged upfront, none of which make the facility cheaper. The monthly payment is a cash flow fact, useful for the cash flow forecast in the business-plan skill, and it is never the number this comparison is sorted by.

8. **Record what is missing rather than filling it in.** A quote with no stated arrangement fee is not a quote with a zero arrangement fee. It is a quote with an unknown one, and it stays out of the ranked comparison until the figure is confirmed in writing, because ranking an incomplete quote against complete ones produces a false winner.

9. **Hand the arithmetic, the sorting and the file building to Codex, and keep the reading of the regulations here.** Write the inputs into a working folder, then run:

   ```
   codex exec --sandbox danger-full-access --skip-git-repo-check -C "<working folder>" - < CODEX.md
   ```

   Claude hands over every quote exactly as the lender or broker stated it, the legal form of the business, whether a broker is involved and their answer on commission, and the early settlement clause as written in each contract. Codex returns the total cost of credit table sorted ascending, the cost per 1,000 pounds figure, the regulated status column, the broker disclosure record and the gap list. Codex decides nothing about which offer suits the business.

10. **Finish with the ranked table on one page and date it.** Cheapest total cost of credit at the top, dearest at the bottom, every incomplete quote listed separately underneath with what is missing, and the date every quote was read. A comparison built from quotes that have since expired is worse than no comparison at all, because it looks current.

## Then it checks

1. Every quote row states the rate, every fee with its basis, the term and any final payment, and no cell reads typical, around or approximately.
2. Every quote carries a regulated status of exactly regulated, exempt business lending or company borrowing, with the amount and legal form it was tested against.
3. The total cost of credit is calculated in pounds for every complete quote, and no ranking is produced from a percentage rate alone.
4. Every quote states its early settlement position as read from the actual contract clause, or states that no clause was supplied, and never states that a statutory rebate applies without confirming the agreement is regulated.
5. Where a broker is involved, the file records whether a commission disclosure was given and what it said, separately from the loan's own regulated status.
6. Every incomplete quote is listed separately from the ranked table with the exact figure missing, and no incomplete quote appears in the ranking.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never state a typical business lending rate, a normal fee percentage, an average total cost of credit or a usual APR for an independent UK hospitality business. No published figure exists for a single independent business, and any figure that circulates is either a headline rate designed to look small or a broker's own marketing.
- Never rank an incomplete quote against a complete one. A missing fee is a gap, not a zero, and a quote with a gap does not compete until the gap is closed.
- Never assume a statutory early settlement rebate applies to an exempt business loan. That protection is written into regulations that name their own scope as regulated consumer credit agreements, and an exempt business facility is not one.
- Never treat a broker's silence on commission as evidence there is none. Where a regulated credit broker is involved, ask directly and record the answer, because the disclosure duty exists precisely because the arrangement is not always obvious from the quote itself.
- Never sort or present a comparison by monthly payment. It is recorded for the cash flow forecast and never used to rank cost.
- This output is a working document prepared for the owner to check against their own quotes and contracts, and for their own accountant to review on affordability and tax treatment. Where any quote is regulated credit, involves a broker, or any security is a personal guarantee or a charge over a home, it is also for their own solicitor and an FCA authorised adviser. It is not advice, it is not a recommendation to take any product, and it is not a statement that any quote is still available on the terms recorded.

## Built from
- The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, article 60C, https://www.legislation.gov.uk/uksi/2001/544/article/60C, stated on the page as up to date with all changes known to be in force on or before 23 September 2026, read 23 September 2026: the exemption for business credit exceeding £25,000 in step 1 and step 3.
- British Business Bank, "Business finance glossary", https://www.british-business-bank.co.uk/business-guidance/business-finance-glossary, no publication date shown on the page, read 23 September 2026: the APR definition and comparison statement in step 1.
- British Business Bank, "What are the different types of business loan?", https://www.british-business-bank.co.uk/business-guidance/guidance-articles/finance/what-are-the-different-types-of-business-loan, no publication date shown on the page, read 23 September 2026: the recommendation to review APR including fees, in step 1.
- Committee of Advertising Practice, CAP Code (Edition 12), Section 14 "Financial products", https://www.asa.org.uk/type/non_broadcast/code_section/14.html, no publication date shown on the page, read 23 September 2026: rules 14.2 and 14.3 on the minimum disclosure required in financial marketing not regulated by the FCA, in step 3.
- The Consumer Credit (Early Settlement) Regulations 2004, regulation 2, https://www.legislation.gov.uk/uksi/2004/1483, read 23 September 2026: the statutory rebate scoped to a regulated consumer credit agreement, in step 5.
- The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, article 36A, https://www.legislation.gov.uk/uksi/2001/544/article/36A, read 23 September 2026: credit broking remaining a regulated activity even where the underlying agreement is exempt, in step 6.
- FCA Handbook, CONC 3.7, https://www.handbook.fca.org.uk/handbook/CONC/3/7.html, page marked as updated within the current Handbook, read 23 September 2026: the broker commission disclosure duty in step 6.

# loan-comparison

## You are given
One UK business holding two or more real finance quotes it wants compared. The legal form of the business and, for a partnership, the number of partners and how many are bodies corporate. For each quote: the lender name, the product name, the amount, the rate and whether it is fixed or variable, every fee with its name, amount and basis, the term in months, the repayment frequency, any final or balloon payment, and the early settlement clause exactly as written in the contract, or a statement that none was supplied. For each quote, whether a broker introduced it, the broker's name, and if a broker is involved, the broker's own answer on whether they receive a payment or other benefit from the lender in connection with the introduction, recorded in the broker's own words. The date and source document name for every figure. All judgement calls, including which quotes to gather, have already been made by the owner and are supplied to you.

## Produce
Write into a `./loan-comparison-output/` folder:

1. `quotes.csv` with these columns in this order: `quote_ref`, `lender_name_verbatim`, `product_name_verbatim`, `amount_gbp`, `rate_percent`, `rate_basis`, `term_months`, `repayment_frequency`, `fee_name`, `fee_amount_gbp`, `fee_basis`, `final_payment_gbp`, `figure_source`, `figure_date`, `complete`. `quote_ref` is Q001 upward, one row per fee where a quote has more than one fee. `rate_basis` is exactly one of `fixed`, `variable`, `not stated`. `fee_basis` is exactly one of `one off`, `per annum`, `percentage of advance`, `not stated`. `complete` is `yes` only where the amount, rate, term and every fee needed to calculate total cost are present with no gap.
2. `regulated-status.md` stating, for each `quote_ref`, the amount, the legal form of the borrower, whether the credit exceeds £25,000, and the resulting status of exactly `regulated`, `exempt business lending` or `company borrowing`, each line naming the supplied figure it rests on.
3. `total-cost.csv` with columns: `quote_ref`, `lender_name_verbatim`, `amount_gbp`, `sum_of_fees_gbp`, `sum_of_interest_or_rentals_gbp`, `total_payments_gbp`, `total_cost_of_credit_gbp`, `cost_per_1000_borrowed_gbp`, `rank`. `total_cost_of_credit_gbp` is `total_payments_gbp` minus `amount_gbp`. `cost_per_1000_borrowed_gbp` is `total_cost_of_credit_gbp` divided by `amount_gbp` multiplied by 1000. Sorted ascending by `total_cost_of_credit_gbp`. Rows where the corresponding `quotes.csv` rows are not all `complete` are placed at the end with `rank` left empty and listed in `gaps.md`.
4. `early-settlement.csv` with columns: `quote_ref`, `clause_supplied`, `clause_text_verbatim`, `statutory_rebate_applies`. `clause_supplied` is `yes` or `no`. `statutory_rebate_applies` is `no` in every row where `regulated-status.md` records that quote as `exempt business lending` or `company borrowing`, and `not determined` only where the regulated status itself could not be determined.
5. `broker-disclosure.csv` with columns: `quote_ref`, `broker_involved`, `broker_name_verbatim`, `commission_disclosure_given`, `disclosure_text_verbatim`. `broker_involved` is `yes` or `no`. Where `broker_involved` is `yes`, `commission_disclosure_given` is `yes`, `no` or `not stated`, and any row reading `no` or `not stated` is listed in `gaps.md`.
6. `ranked-comparison.md` listing every `complete` quote in ascending order of `total_cost_of_credit_gbp` with the lender name, the amount, the term and the total cost stated on one line each, followed by a separate list of every incomplete quote with the exact figure missing.
7. `gaps.md` a numbered list of: every quote row missing a rate, a fee amount, a term or a final payment figure; every figure supplied without a source document name and date; every broker-involved row with no commission disclosure recorded; every quote excluded from ranking and the exact figure missing; and any supplied text containing an em dash character.

## Rules
- Codex sorts, totals and records. It never chooses a quote, never estimates a missing fee or rate, and never decides a regulated status beyond applying the supplied numeric and business purpose test.
- Never estimate a rate, a fee or a total cost. A missing figure leaves the cell empty, marks the row `complete` as `no`, and produces a line in `gaps.md`. A part costed quote is never ranked.
- Never write a benchmark figure of any kind into any file: no typical rate, no typical fee, no average total cost of credit, no normal APR. None exists for a single independent UK hospitality business and none is to be recorded.
- Never mark `statutory_rebate_applies` as `yes` for any row recorded as `exempt business lending` or `company borrowing`, regardless of what a quote's own marketing wording claims about early repayment.
- Never mark `commission_disclosure_given` as `yes` without a supplied disclosure text. Silence from a broker is recorded as `not stated`, never inferred as `no commission paid`.
- Never sort or rank any file by the rate percentage or the monthly payment. The only ranking column is `total_cost_of_credit_gbp`.
- Use British English, GBP written as `GBP` or the pound sign, and DD Month YYYY dates. No em dash characters in any file you write, and any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every quoted lender name, product name, broker name and clause is copied exactly, including its punctuation and capitalisation.
- Every file ends with this line: this is a working document prepared for the owner to check against their own quotes and contracts, and for their own accountant to review on affordability and tax treatment, and for their own solicitor and an FCA authorised adviser where any quote is regulated credit, involves a broker, or any security is a personal guarantee or a charge over a home. It is not advice and it is not a recommendation to take any product.

## Return
The absolute path of every file written, the row count of each CSV, the count of complete and incomplete quotes, the ranked list of complete quotes by total cost of credit with the pounds figure for each, the cheapest and the dearest total cost of credit figures and the gap between them in pounds, the regulated status counts by category, the count of quotes involving a broker and how many carried a recorded commission disclosure, the count of quotes with an early settlement clause supplied, and the gaps.md item count.